California’s Clean Truck Check: New Name for Heavy-Duty Inspection and Maintenance Rule

What the California Air Resources Board (CARB) formerly called its Heavy-Duty Inspection and Maintenance Regulation (HD I/M) has been rebranded as the “Clean Truck Check” Regulation.

Nearly all diesel and alternative fuel heavy-duty trucks, buses, and other vehicles with a gross vehicle weight rating over 14,000 pounds that operate in California are subject to semiannual testing and compliance, regardless of the state they are based in. Affected vehicles include hybrid trucks and buses, commercial vehicles, privately-owned vehicles, government vehicles, and vehicles registered outside of California.

CARB opened a registration period on October 1, 2023, for registering affected vehicles in its Clean Truck Check Vehicle Inspection System (CTC-VIS). The database can be accessed at cleantruckcheck.arb.ca.gov or an owner can register its vehicle(s) at https://ww2.arb.ca.gov/our-work/programs/truckstop-resources/truckstop.  CARB extended its deadline so that any vehicle(s) subject to Clean Truck Check must be reported in the database, and the first annual compliance fee of $30.00 per vehicle paid by January 31, 2024. If a vehicle owner fails to create an owner account and pay the initial compliance fees, the owner may be cited for non-compliance and/or have their DMV vehicle registrations blocked.

In 2024, since there is only one emissions testing requirement for that year, the registration fee must be paid by the last day of the month as noted in the table below. Depending on the date of the vehicle’s DMV/outside-of-California registration expiration, the compliance fee must be paid as follows:

Vehicle’s DMV Registration Expires	Clean Truck Compliance Fee Due Last Day of
January or July	July
February or August	August
March or September	September
April or October	October
May or November	November
June or December	December

Beginning in 2025, the compliance fee must be paid annually based on the last number of the vehicle's VIN.

Vehicle’s VIN Number Ends in	Clean Truck Compliance Fee Due Last Day of
0	October
1	November
2	December
3	July
4	August
5	September
6	October
7	November
8	December
9	July

You can receive regular updates on Clean Truck Checks directly from CARB by signing up for email alerts at https://public.govdelivery.com/accounts/CARB/subscriber/new?topid=hdim.

Roadside Inspections.

CARB rolled out Phase 1 of its new requirements in January 2023, conducting roadside inspections using roadside emissions monitoring to identify high-emitting vehicles. When CARB’s roadside monitoring picks up a vehicle that potentially violates the emissions standards, it will send a notice to the owner (Notice to Submit to Testing or NST) which requires the owner to submit a passing Clean Truck Check test to CARB within 30 days. Roadside monitoring will continue even after the full periodic testing and reporting requirements are in place.

Currently, vehicle compliance tests are only required if the owner receives an NST. Upon receiving an NST, a passing vehicle compliance test is required within 30 days of receipt.

 Periodic inspections enforcement.

On December 29, 2023, CARB established that the effective date for section 2196.2 of the HD I/M regulation (periodic inspection) is April 1, 2024. Vehicles subject to the Clean Truck Check regulation must pass an emissions compliance test twice per year, except motorhomes and agricultural vehicles, which must pass an emissions compliance test once per year. The first periodic testing submission deadlines will occur in July of 2024.  CARB will also notify vehicle owners through outreach activities such as training sessions, targeted email campaigns and program announcements delivered straight to your email inbox when you subscribe to receive Clean Truck Check program updates at https://public.govdelivery.com/accounts/CARB/subscriber/new?topid=hdim. Nearly all vehicles will be required to undergo semiannual testing with results submitted to CARB. Three years after the start of Clean Truck Check periodic compliance testing, no earlier than January 2027, most vehicles will be required to undergo testing four times per year.

Timing of testing.

For California-registered vehicles, the compliance testing deadlines are linked to each vehicle’s DMV registration expiration/renewal date. Passing Clean Truck Check test results may be submitted up to 90 days before a compliance deadline, but certainly no later than the vehicle’s registration renewal date.

For vehicles registered outside of California and those vehicles without DMV registration requirements (e.g., public agency vehicles, some federal vehicles), semiannual compliance deadlines are based on the last number of a vehicle’s VIN as shown in the table below. Passing Clean Truck Check test results may be submitted up to 90 days before a compliance deadline but must be submitted no later than the compliance deadline itself.

VIN   ending in	First test     results due	Second test     results due
0	April   30	October   31
1	May   31	November   30
2	June   30	December   31
3	July   31	January   31
4	August   31	February   28/29
5	September   30	March   31
6	October   31	April   30
7	November   30	May   31
8	December   31	June   30
9	January   31	July   31

Following the initial three years of periodic testing requirements, the compliance testing frequency increases to four times per year on April 1, 2027, for vehicles equipped with onboard diagnostics systems.

For more information, please contact The Cullen Law Firm PLLC at info@cullenlaw.com